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Tax Brief PMK 55/2026: Aturan Baru Konsultan Pajak dan Kuasa Wajib Pajak

Tax Brief PMK 55/2026: New Rules for Tax Consultants and Taxpayer Legal Representatives

KUP

30 Sep 2026, 02.39 WIB

Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 55 of 2026 concerning Tax Consultants and Other Parties Acting as Taxpayer Legal Representatives was issued in Jakarta on July 22, 2026 and promulgated on August 24, 2026, in the State Gazette of the Republic of Indonesia Number 589 of 2026.

 

PMK Number 55 of 2026 regulates tax consultants and other parties acting as taxpayer legal representatives. Previously, regulations on the development and supervision of tax consultants did not cover other parties acting as taxpayer legal representatives.

 

This tax brief discusses the basis, structure, and primary provisions of PMK Number 55 of 2026 and compares them with the previous regulations.

 

Basis and Backgrounds

 

PMK Number 55 of 2026 sets out three main considerations. First, the enactment of Law of the Republic of Indonesia Number 4 of 2023 concerning Financial Sector Development and Strengthening, as amended by Law of the Republic of Indonesia Number 4 of 2026, and Law of the Republic of Indonesia Number 6 of 2023 concerning the Stipulation of Government Regulation (Peraturan Pemerintah/PP) in Lieu of Law of the Republic of Indonesia Number 2 of 2022 concerning Job Creation into Law requires further implementing regulations. These regulations are intended to improve the professionalism and integrity of tax consultants as tax intermediaries within the national tax system.

 

Second, PMK Number 111/PMK.03/2014 concerning Tax Consultants, as amended by PMK Number 175/PMK.01/2022, did not regulate the development and/or supervision of other parties acting as taxpayer legal representatives.

 

Third, PMK Number 55 of 2026 was issued to implement the mandate under Article 259(6) of the Law of the Republic of Indonesia concerning the Financial Sector Development and Strengthening and Article 53 of PP Number 50 of 2022 concerning Procedures for Exercising Tax Rights and Fulfilling Tax Obligations.

 

Structure of the Regulation

 

PMK Number 55 of 2026 comprises seven chapters:

  • Chapter I sets out general provisions, including definitions and the Minister of Finance's authority to develop, foster, and supervise tax consultants, tax consulting firms, and other parties acting as taxpayer legal representatives.
  • Chapter II regulates tax consultants, covering licensing, permissible services, tax consulting firms, obligations and prohibitions, membership in professional associations, development and supervision, and administrative sanctions.
  • Chapter III regulates the temporary suspension of services, resignation, and the expiration of tax consultant licenses.
  • Chapter IV regulates other parties acting as taxpayer representatives.
  • Chapter V establishes the Tax Consultant Professionalism Committee.
  • Chapter VI contains transitional provisions.
  • Chapter VII contains concluding provisions, including the revocation of previous regulations and the effective date of PMK Number 55 of 2026.
  •  

Three Levels of Tax Consultant Licenses

 

PMK Number 55 of 2026 retains three levels of tax consultant licenses: levels A, B, and C. A level A license authorizes the provision of tax services to individual taxpayers, except individuals domiciled in tax treaty partner countries.

 

A level B license covers services provided to individuals and entities, except foreign investment entities, permanent establishments, and parties domiciled in tax treaty partner countries. Meanwhile, a level C license authorizes services to all individuals and entities without exception.

 

To obtain a tax consultant license, an individual must satisfy several requirements, including being an Indonesian citizen, possessing tax expertise evidenced by a certificate of competency, passing the tax consultant professional examination administered by the Tax Consultant Association, and holding at least a bachelor's degree (S-1).

 

Applicants must also not be employees or officials of government institutions, state-owned enterprises, or municipal enterprises.

 

Tax Consulting Firms and Business Structure

 

PMK Number 55 of 2026 provides that a tax consulting firm may be a sole proprietorship, civil partnership, partnership, or limited liability company. PMK Number 111/PMK.03/2014 did not previously regulate the limited liability company.

 

For a tax consulting firm established as a limited liability company, at least one tax consultant must establish the company, and a board of directors and a board of commissioners must manage it, with a majority of members being tax consultants. The regulation also governs the name of a tax consulting firm, changes of address, changes to its management structure, and the firm's closure. The firm must report any such change to the Director General of Taxes (DGT) within 30 days.

 

Obligations, Prohibitions, and Administrative Sanctions

 

PMK Number 55 of 2026 fortifies the obligations and prohibitions applicable to tax consultants. Tax consultants must provide services within the scope of their licenses, comply with professional codes of ethics and practice standards, maintain independence, and avoid conflicts of interest, including those arising from family relationships with employees of tax policy-making units.

 

Tax consultants must also be members of the Tax Consultant Association, meet the annual continuing professional education credit requirements for their license level, and submit annual reports. These annual reports must include details of the services provided to each client.

 

Tax consultants are prohibited from providing misleading information to clients, offering or accepting remuneration in connection with tax officials, and concurrently holding positions as employees of government or state-owned enterprises.

 

Violations may result in administrative sanctions imposed progressively, ranging from warnings and license suspensions to license revocation. A warning or suspension imposed three times within the preceding five years may serve as a basis for imposing a more severe sanction.

 

Regulation for Other Parties Acting as Taxpayer Legal Representatives

 

For the first time, PMK Number 55 of 2026 specifically regulates other parties acting as taxpayer legal representatives through Chapter IV. These other parties are individuals, other than tax consultants and family members, who have obtained a tax registration certificate and have been appointed by taxpayers as legal representatives under applicable laws and regulations.

 

The provisions concerning licensing, competency examinations, prohibitions, and administrative sanctions applicable to tax consultants also apply mutatis mutandis to such other parties. A tax registration certificate is issued together with a certificate of competency, valid for three years.

 

Under this arrangement, the Ministry of Finance brings other parties acting as taxpayer legal representatives into its development and supervision scheme.

 

Tax Consultant Professionalism Committee

 

PMK Number 55 of 2026 establishes the Tax Consultant Professionalism Committee, appointed by a Minister of Finance Decree for a three-year term.

 

The committee consists of a steering committee and a secretariat. The steering committee comprises seven members representing the Ministry of Finance, the Tax Consultant Association, and scholars.

 

The steering committee develops practice standards and codes of ethics, establishes taxation competency standards, and determines policies for administering competency examinations and continuing professional education.

 

The committee represents a new institutional framework for regulating tax consultants.

 

Comparison with Previous Regulations

 

Before PMK Number 55 of 2026 took effect, tax consultants were regulated under PMK Number 111/PMK.03/2014 concerning Tax Consultants, as amended by PMK Number 175/PMK.01/2022. Both regulations were revoked and declared no longer effective upon the promulgation of PMK Number 55 of 2026.

 

The main difference lies in the expanded regulatory scope.  PMK Number 55 of 2026 specifically regulates other parties acting as taxpayer legal representatives, which the tax consultant regulations did not previously cover.

 

PMK Number 55 of 2026 also introduces several changes, including:

  1. The term practice license used in the previous regulations is replaced with tax consultant license.
  2. The Tax Consultant Association administers professional examinations, replacing the committee responsible for tax consultant certification.
  3. A competency examination is introduced, resulting in a certificate of competency valid for three years.
  4. A certificate of competency is one of the requirements an individual must meet before taking the professional examination and obtaining a tax consultant license.
  5. The permitted business structure for tax consulting firms is expanded to include limited liability companies.
  6. The supervision distinguishes between regular examinations and special examinations.
  7. The Tax Consultant Professionalism Committee is established as part of the profession's institutional governance.

 

Transitional Provisions

 

PMK Number 55 of 2026 contains several provisions to ensure continuity of existing licensing and administrative processes. Practice licenses issued under the previous regulations remain valid and are deemed to be tax consultant licenses.

 

Applications for licenses and tax consultant administrative services that remain in process continue to use the requirements under the previous regulations. At the same time, they must be completed under the rules set out in PMK Number 55 of 2026.

 

Tax consultant certificates issued under the previous regulations remain valid as certificates of competency for up to two years. Certificate holders must take the professional examination after the Tax Consultant Association begins administering it, no later than December 31, 2026.

 

Conclusion

 

PMK Number 55 of 2026 updates the regulatory framework for tax consultants while expanding its scope to other parties acting as taxpayer legal representatives. The regulation also changes competency and licensing procedures, expands the permitted business structures for tax consulting firms, improves obligations and supervision, and establishes a Tax Consultant Professionalism Committee.

 

Tax consultants, tax consulting firms, professional associations, and taxpayers engaging legal representatives should consider these changes when exercising their tax rights and fulfilling their tax obligations.

 

Legal References

  • Law of the Republic of Indonesia Number 6 of 1983 concerning General Provisions and Procedures of Taxation, as amended by Law of the Republic of Indonesia Number 6 of 2023 concerning the Stipulation of Government Regulation in Lieu of Law of the Republic of Indonesia Number 2 of 2022 concerning Job Creation into Law.
  • Law of the Republic of Indonesia Number 39 of 2008 concerning State Ministries, as amended by Law of the Republic of Indonesia Number 61 of 2024 concerning Amendments to Law of the Republic of Indonesia Number 39 of 2008 concerning State Ministries.
  • Law of the Republic of Indonesia Number 4 of 2023 concerning Financial Sector Development and Strengthening, as amended by Law of the Republic of Indonesia Number 4 of 2026 concerning Amendments to Law of the Republic of Indonesia Number 4 of 2023 concerning the Financial Sector Development and Strengthening.
  • Government Regulation Number 50 of 2022 concerning Procedures for Exercising Tax Rights and Fulfilling Tax Obligations.
  • Presidential Regulation Number 158 of 2024 concerning the Ministry of Finance.
  • Minister of Finance Regulation Number 124 of 2024 concerning the Organization and Work Procedures of the Ministry of Finance, as amended by Minister of Finance Regulation Number 117 of 2025 concerning Amendments to Minister of Finance Regulation Number 124 of 2024 concerning the Organization and Work Procedures of the Ministry of Finance.
  • Minister of Finance Regulation Number 111/PMK.03/2014 concerning Tax Consultants, as amended by Minister of Finance Regulation Number 175/PMK.01/2022 concerning Amendments to Minister of Finance Regulation Number 111/PMK.03/2014 concerning Tax Consultants, which was revoked and declared no longer effective upon the promulgation of Minister of Finance Regulation Number 55 of 2026.

 

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